Monday, July 29, 2013

EPA Documents Show U.S. Goal to Harmonize with Codex Alimentarius

In many of the articles I have written regarding Codex Alimentarius, as well as in my book Codex Alimentarius – The End of Health Freedom,
I have mentioned the stated goals of Codex Alimentarius, national
governments and, hence, government agencies to harmonize domestic laws,
regulations, and policies as the Codex guidelines are established.

Yet, while some may doubt the veracity of this claim, it can be no
clearer than the statement provided by the EPA in their own
Reregistration for Eligibility Decision documents for pesticides that
harmonization with Codex guidelines is the intention of the U.S.
government.

Although virtually all of the Reregistration Eligibility Decision (RED)
documents contain essentially the same prescripts and tangential
information, one need only to take a look at one of the documents – the
document dealing with Acephate for the purposes of this article – to
locate the statement of purpose to harmonize Codex guidelines and those
of the EPA. It says,

The Codex Alimentarius
Commission has established several maximum residue limits (MRLs) for
residues of acephate in/on various plant and animals commodities. The
Codex MRLs are expressed in terms of acephate per se. Harmonization of
expression/definition between Codex MRLs and U.S. tolerances will be
achieved when the residue definition of the U.S. tolerances is changed
from combined residues of acephate and the metabolite methamidophos to
acephate per se. A numerical comparison of the Codex MRLs and the
corresponding reassessed U.S. tolerances is presented in Table 16.
Recommendations for compatibility are based on conclusions following
reassessment of U.S. tolerances (see Table 15.)[1]

This
statement of intended harmonization with Codex standards is included in
virtually every one of the Reregistration for Eligibility Decision (RED)
documents.

Interestingly enough, these statements not only openly announce their
intentions of harmonization, but clearly state that the U.S. will amend
its standards to meet those of Codex Alimentarius. These pesticides are
continually reassessed for these reasons.

Indeed, the charts presented in the RED documents contain figures for
the “reassessed” MRLs in comparison to those of Codex. But while
changing scientific conclusions for political purposes is not only
unscientific, it is also highly deceptive and unethical. Yet this is
what the EPA admits to doing in its own documents.

Obviously, neither the science nor the evidence will change simply
because governments have entered into an agreement. However, it appears
that the methods used to achieve such conclusions, as well as the
conclusions themselves will do just that.

Continuing with Acephate as an example, one can see harmonization in
action. When one looks at the MRLs set by Codex and those set by the
EPA, two things are readily apparent. First, in this particular case,
the MRLs of Codex are set much higher than those of the EPA. Second,
many of the “reassessed” U.S. MRLs are compatible with those of Codex.

The following values are expressed in ppm. Once converted, ppm is the same value as the mg/kg designation that Codex uses.

Codex and EPA MRLs for Acephate

Brussels Sprouts = EPA 3.0/CODEX 5

Cattle Fat = EPA TBD/CODEX 0.1

Cattle Meat = EPA TBD/CODEX 0.1

Cauliflower = EPA 2.0/CODEX 5

Cotton Seed = EPA 0.5/CODEX 2

Eggs = EPA 0.1/CODEX 0.1

Lettuce, Head = EPA 10.0/CODEX 5

Milks = EPA TBD/CODEX 0.1

Pig Fat = EPA TBD/CODEX 0.1

Pig Meat = EPA TBD/CODEX 0.1

Poultry Fats = EPA 0.1/CODEX 0.1

Poultry Meat = EPA 0.1/CODEX 0.1

Soya Bean (dry) = EPA 1.0/CODEX 0.5[2]

Here, compatibility exists in three categories (eggs, poultry fats,
and poultry meats). With the exception of lettuce, all Codex MRLs are
higher than the EPA limits. All of the EPA limits have been “reassessed”
after the introduction of Codex MRLs. The differences in the upper
limits are attributed to “differences in agricultural practices in the
U.S. upon which the residue data were developed.”[3]

This may be true, of course, but it is also a convenient excuse. As
stated earlier, it appears that true scientific practice is taking a
backseat to political considerations in the arena of pesticide MRLs and
Codex harmonization.

Yet even with the stated goal of harmonization, it appears that the
levels of “acceptable” pesticide residues in food will not go down. That
is, at least from the EPA’s standpoint. When one observes the MRL list
for substances such as Dicofol, a pesticide in which the EPA’s
tolerances are generally higher than that of Codex’s own, the EPA tends
to remain resolute in its position.

For instance, Codex sets a Dicofol MRL of 0.1 while the EPA sets an MRL
of 0.5.[4] However, whereas the EPA “reassesses” its tolerances for
substances such as Acephate as demonstrated above, in this case it
states, “Data do not support a lower US tolerance, with field trial
residues as great as 0.4 ppm.”

For dry hops, Codex sets the MRL at 50 mg/kg. The EPA sets the value at
65 ppm.[5] In this case as well, the EPA remains firm saying, “Data
indicate that the tolerance cannot be decreased.”[6]

Apparently, the EPA is capable of standing up to Codex when it comes to
harmonizing its own standards to higher acceptable levels of
contamination, but not for lower ones. As I have discussed in previous articles,
this opens the door to the WTO dispute resolution mechanism to address
pesticide MRL’s. It may be in the WTO “court” that the issues of MRLs
for pesticide residues are resolved.

While such disregard for the welfare and concerns of consumers is to be
expected of Codex, it is nonetheless still hypocritical. This is most
evident by examining the procedures being followed for pesticide
residues when compared to those used when assessing vitamin and mineral supplements.[7]

However, some telling comments were made by the (Food and Agricultural Organization) FAO on its own website regarding the Revised Guidelines for Predicting Dietary Intake of Pesticide Residues.

In reference to these guidelines it states, “The use of these guidelines
should significantly reduce the number of cases where exposure
assessments cause unnecessary concern.”[8] While few would argue that
this statement is unreasonable, it is without doubt a completely
different mindset than that guiding the Codex Committee on Nutrition and Foods For Special Dietary Uses[9] (CCNFSDU) in regards to natural supplements.

Indeed, it seems that the purpose of the CCNFSDU is to “cause
unnecessary concern” regarding vitamins and minerals. When it comes to
pesticides however, the standards are quite a bit looser.

Again, in regards to the Revised Guidelines for Predicting Dietary Intake of Pesticide Residues, the same document continues by saying,

The Guidelines explicitly state that a
worst-case estimate is a gross overestimate of true exposure and that
more refined calculations should be performed using other relevant data.
However, some Members of CCPR reject MRLs when this additional data is
not available. Others rely, for instance, on monitoring data, which may
demonstrate that no exposure problems are to be expected.[10]

This
statement, taken on its own, might not seem like a reason for consumers
to rise up in arms. However, not only does it downplay what it
considers to be the worst-case scenario but it also admits to a
potential bias toward conclusions that determine there are no exposure
problems. It is also quite misleading to suggest that a gross
overestimate of true exposure of pesticides is a trivial matter. To
overestimate the exposure of populations, such as in the Global Expectable Average Daily Diet[11] for vitamins and minerals,[12]
is to overestimate the tolerances (depending on which scientific model
is chosen) of those populations, possibly leading to even higher MRL and
acceptable tolerances of pesticide residues in foods.

Ultimately, however, whether the acceptable levels of pesticide residue
in foods are moved up or down, it cannot be argued that the goal is to
harmonize domestic U.S. standards with the international Codex
Alimentarius Guidelines. After all, such a goal has been stated by the
EPA itself within its own RED documents.

With this in mind, it would be wise for all American consumers to more
closely monitor the decisions of their domestic regulatory agencies.

Afraa Dagher Twitter

Syriana Afraa

Eva Bartlett

Observations from Occupied Palestine: Gaza – In Gaza

Quoth The Raven, "Veritas"

Translate

Support BrandonTurbeville.com!

Please help support the website by shopping with our Amazon link by clicking on the icon above. It will cost you nothing extra but you can still help support the site simply by clicking on the link above before adding items to your cart. Your support is much appreciated!

Free PDF: The Difference It Makes: 36 Reasons Why Hillary Clinton Should Never Be President